ML20058B765
| ML20058B765 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 07/22/1982 |
| From: | Mizuno G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8207260138 | |
| Download: ML20058B765 (8) | |
Text
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e' 07/22/82 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMf11SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY
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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)
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NRC STAFF'S SUPPLEMENTAL ANSWER TO NATURAL RESOURCES DEFENSE COUNCIL, INC.
AND THE SIERRA CLUB TWENTY-SECOND SET
_ 0F INTERROGATORIES TO STAFF The Nuclear Regulatory Comission Staff (" Staff") hereby supplements its April 28, 1982 response to the Natural Resources Defense Council, Inc. and the Sierra Club Twenty-Secend Set of Interrogatories to Staff, filed on March 18, 1982. Attached hereto are the Staff's answer to Interrogatory 1 regarding Contention 11 of the Twenty-Second Set of Interrogatories, together with the affidavit of Michael Bender.
In the April 14, 1982 Order Following Conference with Parties, the Licensing Board renumbered NRDC's contentions. When an old contention number appears in the interrogatory, the new contention number will be indicated in parentheses.
Respectfully submitted, Geary S. Mizuno Counsel for NRC Staff Dated at Bethesda, Maryland this 22nd day of July,1982 ggDORIGIN)Il\\
3 31 uc Certified By_
D SD ']
8!207260139 820722 PDR ADOCK 05000537 G
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I NRC STAFF'S ANSWER TO NRDC'S AND THE SIERRA CLUB INTERR0GATORY 1 REGARDING CONTENTION 11, TWENTY-SECOND SET OF INTERR0GATORIES TO STAFF Contention 8a (renumbered as 11)
Interrogatory 1 John W. Gofman argues, in Radiation and Human Health, Sierra Club Books 1981, pp. 760-853, that the BEIR I, III and UNSCEAR (1977) estimates of generic risk from radiation exposure do not adequately account for many irregularly inherited diseased and consequently they underestimate the genetic effect of radiation exposure with respect to irregularly inherited diseases by a factor between 6 and 100.
(See Gofman, supra, page 791.)
If Staff disagrees with Gofman's analysis in this regard or if Staff disagrees with Gofman's estimate of the total of all genetic and chromosomal diseases or defects (at page 849) please explain precisely the nature of your disagreement.
Answer 1 Staff disagrees with Dr. John W. Gofman's analysis of genetic risk from radiation exposure as presented in Radiation and Human Health, Sierra Club Books 1981, pp. 760-853, and believes that the BEIR (and UNSCEAR, 1977) estimates of genetic risk from radiation exposure do adequately account for many irregularly inherited diseases and consequently they do not underestimate the genetic effect of radiation exposure. Staff further disagrees with Gofman's estimate of the total of all genetic and chromo-somal diseases or defects as presented in his Table 76 on pages 848 and 849.
Gofman's upper bound estimates for irregularly inherited diseases and for chromosomal diseases are far higher than those of the BEIR III and UNSCEAR (1977) Cormittees.
In the case of the irregularly inherited diseases Gofman disputes two elements of the Committee's estimates:
that of current incidence and that of mutational component. He argues I
2_
t that the former is "probably 3 to 5 times too low, because important diseases of adulthood with a genetic component are simply not listed by various quasi-governmental comittees." However the BEIR III Comit-tee clearly believed that the current incidence estimate of "at least 9%"
comprises a far larger fraction of such disease having a significant genetic component (i.e. responsiveness to mutation pressure) than Gofman believes. Furthermore, the diseases occurring later in life appear generally to have a smaller (or more complex) genetic component, so their incidence should be less sensitive to increased mutation.
The BEIR III Comittee estimates the mutational component of irregularly inherited disease as being the range 5-50%; the UNSCEAR Comittee estimates for the mutational component of such diseases as 5%.
Clearly, these are estimates of the average, and the wide range adopted the BEIR III Comittee shows that geneticists differ considerably among themselves.
It is notable that the UNSCEAR (1977) Comittee clearly felt that values even as large as 50% are implausible. Gofman argues that these estimates are the product of " sheer, unsupported speculation,"
and adopts a value of 100% for his calculations. But this is simply incompatible with mendelian genetics, for 100% is the value for the regularly inherited diseases, and the value for irregularly inherited diseases of complex etiology must be less.
In fact, the two elements, incidence of irregularly inherited diseases and the average mutational component, are inter-related and cannot properly be estimated independently as Gofman attempts to do.
.)
. t With respect to chromosomal diseases, Gofman disagrees with the BEIR III and the UNSCEAR (1977) Reports regarding three separate forms of chromosomal aberrations: deletions, translocations and nondisjunction leading to trisomy, especially trisomy 21 or Down's syndrome.
Gofman argues that most deletions are too small to be detected by conventional cytogenetic techniques, and so far "f ar more important than is comonly recognized." However, this ignores the fact that the BEIR III and the UNSCEAR (1977) estimates of doubling dose are not based mainly on human data, but largely on laboratory mouse specific locus mutation data, and these mutations include the deletion class.
Indeed, most of the mutant alleles are homozygous lethal and over two thirds of them are actually large enough to be detected by modern cytogenetic techniques. Moreover, as stated in BEIR 1 (pages 63-64) and reconfirmed in BEIR III (page 104),
"the ratio of deletions and chromosome rearrangements to single base effects is likely to be much higher for radiation-induced than for spontaneous changes."
In estimating induced translocation incidence Gofman relied essentially upon work by Brewen and Preston (1975) that allows calcula-tion of an upper limit of doubling dose for this sort of aberration of about 17 rad, plus the idea (similar to that expressed for deletions) that the true current incidence of induced translocation incidence must be substantially underestimated because of technical limitations. How-ever, the BEIR 111 estimate of first generation effect is based upon empirical data on the induction of heritable phenotypic damage to the skeletal system of the offspring of irradiated mice, and that data includes cases where the phenotypic effect was shown to result from
. l translocations. Thus, Gofman's inference regarding the magnitude of the contribution of translocation induction seems unwarranted. The low esti-mate for chromosomal aberrations including translocations that Gofman disagrees with is based upon mouse and other experimental data, as well as the Brewen and Preston human data, as explained in Note 14 (pages 119-124) in the BEIR III Report. That the induced incidence of heri-table, cytogenetically detectable translocations cannot be as high as Gofman estimates is confirmed by the results of extensive cytogenetic observations on the offspring of irradiated survivors of the atomic bombings of Hiroshima and Nagasaki as reported by Schull, Otake and Neel (1981), Science 213:1220-1227).
Gofman's upper estimate of the induced frequence of trisomy-21 is based upon adoption of a 3 rad doubling dose for this effect, an assump-tion that implies that all trisomy-21 is induced by background radiation.
As noted by Gofman and more extensively in Note 15 (pages 124-126) of the BEIR III Report, the human evidence is conflicting as to whether there is an effect at all.
In fact, the evidence from experimental animals including the mouse indicates that nondisjunction is actually very difficult to induce with radiation at all.
For there (and other) reasons the Staff rejects Gofman's numerical estimates of genetic effects, and believes that the lower estimates of the BEIR I, UNSCEAR (1977) and BEIR III Reports are more consistent with the total body of relevant data.
In fact, Schull, Otake and Neel's recent reevaluation of the genetic studies done at Hiroshima and Nagasaki suggests that even these estimates are likely if any thing to be on the high rather than the low side.
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
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UNITED STATES DEPARTMENT OF ENERGY
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Docket Nos. 50-537 PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )
AFFIDAVIT OF MICHAEL BENDER I, Michael Bender, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission ("NRC") as a consultant through a contract between the Clinch River Breeder Reactor Program Office, NRC, and Brookhaven National Laboratories.
2.
I am employed by the Brookhaven National Laboratories as a Senior l
Scientist in the Medical Department.
3.
I am duly authorized to answer Interrogatory I regarding Contention 11 of NRDC's Twenty-Second Set of Interrogatories, dated March 18, 1982, and I hereby certify that the answer given is true to the best of my knowledge.
NicA b
hb Michael Bender Subscribed and sworn to before me this /9M day of July,1982.
i cal A NOTARY PUBLIC My Commission expires: Jn w 3e,/W4 "T;ll,'"', '!:#.f c"." l,"'
,c. M i?/*.*/J.an,m?3
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY
)
Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
)
TENNESSEE VALLEY AUTHORITY
)
(Clinch River Breeder Reactor Plant)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S SUPPLEMENTAL ANSWER TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB TWENTY-SECOND SET OF INTERROGATORIES TO STAFF" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatry Com-mission's internal mail system, this 22nd day of July, 1982:
Marshall Miller, Esq., Chairman (2)
William M. Leech, Jr., Attorney General Administrative Judge William B. Hubbard, Chief Deputy Atomic Safety and Licensing Board Attorney General U.S. Nuclear Regulatory Connission Lee Breckenridge, Assistant Attorney Washington, D.C.
20555
- General 450 James Robertson Parkway Mr. Gustave A. Lir.enberger Nashville, Tennessee 37219 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Cadet H. Hand, Jr., Director William E. Lantrip, Esq.
Administrative Judge City Attorney Bodega Marine Laboratory Municipal Building University of California P.O. Box 1 P.O. Box 247 Oak Ridge, Tennessee 37830
+
Bodega Bay, California 94923 Lawson McGhee Public Library Alan Rosenth:1, Esq., Chairman 500 West Church Street Atomic Safety and Licensing Appeal Knoxville, Tennessee 37902 Board Panel U.S. Nuclear Regulatory Commission Warren E. Bergholz, Jr.
Leon Silverstrom Washington, D.C.
20b55 U.S. Department of Energy Dr. John H. Buck 1000 Independence Ave., S.W.
Atomic Safety and Licensing Appeal Room 6-B-256 U.S. Nuclear Regulatory Conmission Washington, D.C.
205B5 Board Panel Washington, D.C.
20555
r-1 Mr. Joe H. Walker George L. Edgar, Esq.
Frank K. Peterson, Esq.
401 Roane Street Harriman, Tennessee 37830 Gregg A. Day, Esq.
Thomas A. Schmutz, Esq.
Irvin A. Shapell, Esq.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Project Management Corporation P.O. Box U Oak Ridge, Tennessee 37830 Barbara A. Finamore i
Ellyn R. Weiss Dr. Thomas B. Cochran S. Jacob Scherr Natural Resources Defense Council, Inc.
1725 Eye Street, N.W., Suite 600 Washington, D.C.
20006 Manager of Power Tennessee Valley Authority 819 Power Building Chattanooga, Tennessee 37401 Director Clinch River Breeder Reactor Plant Project U.S. Department of Energy Washington, D.C.
20585 Atomic Safety and Licensing ~ Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing an'd Service Section Office of the Secretary a6/c}<'()
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Gepry Sg7MifUno Co0nsel for NRC Staff
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